Moving Money Illegally

Inside the case of an unlicensed money transmittal business that moved more than $172 million.

Moving Money IllegallyA $172 Million Case Example

03/07/11

An Oregon man recently pled guilty to operating an unlicensed money transmittal business that illegally moved more than $172 million in and out of the United States.

As you'll read in a moment, the case is a good example of why it's important to crack down on these shady practices.

The man behind this complex global scheme was Victor Kaganov, a former Russian military officer who emigrated to the U.S. in 1998 and eventually became a naturalized citizen. He created five “shell” corporations—businesses that only existed on paper—in Oregon and began moving money through these bogus companies for his overseas business associates.

Money transmittal businesses in the U.S. are required by federal law to obtain a license from the state where they operate. They are also required to register with the U.S. Treasury. Kaganov did neither.

Instead, he set up accounts under the names of his shell corporations at several Oregon banks. His overseas “clients” would generally wire transfer a substantial amount of money into one of these accounts. Then the clients—through fax or phone—would provide Kaganov with instructions on where to further transmit the funds.

From 2002 to 2009, Kaganov facilitated more than 4,200 wire transactions. A significant portion of the funds transferred into his accounts came from Russia, but the money was transferred out to 50 other countries, mostly in Asia and Europe.

Cooperation was key in this case—we were greatly assisted by the U.S. Treasury, our overseas legal attaches, and our global law enforcement partners.

The Kaganov investigation was a spinoff of a broader FBI case investigating the use of Oregon shell corporations by overseas businesses and individuals to move illicit funds.

Another spinoff of the broader FBI investigation is a brand new hybrid investigative squad in our Portland office focused on any and all threats from Eurasian criminals—one of the FBI’s top organized crime priorities. We call it a “hybrid” squad because it includes agents and analysts from Bureau programs across the board—organized crime, counterterrorism, intelligence, cyber, and counterintelligence.

Why are licensing and registration laws so important? Several years ago, the U.S. government issued a money-laundering assessment that identified money services businesses—especially wire remitters—as a chief conduit for the illicit transmission of money, including funds used to finance all sorts of criminal activity and terrorism. Requirements to register these businesses enable state and federal regulatory agencies to keep a closer eye on what they’re doing.

And whether or not the funds moved through these businesses came from or funded illegal activity, there is other fallout from these businesses. For example, the bank accounts used to facilitate the transfer of money see an awful lot of activity—in Kaganov’s case, there were daily and sometimes even hourly transactions—and that has the potential to destabilize banks. Also, creators of shell corporations often don’t file any tax returns, so they remain unknown to taxing authorities. Or, they keep two sets of financial books—one that they show to taxing authorities and the real one that never sees the light of day.

By thwarting laws and regulations that govern the U.S. financial system, criminals can undermine its integrity. The FBI and its partners are working hard to make sure that doesn't happen.